1143132 Ontario Limited v. The Queen, 2009 DTC 1312, 2009 TCC 477 -- summary under Subsection 2(1)

The central management and control of a Barbados corporation was in Barbados rather than Canada, notwithstanding that its directors in Barbados were described as being inactive, given that there was no evidence that these directors did not, in fact, manage the corporation and it was consistent with the very limited functions of the Barbados corporation that what they did was not much more than the bare minimum.